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OECD publishes further guidance on CBC reporting

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The OECD has published updated consolidated guidance for tax administrations and MNE Groups on the implementation of country by country (CBC) reporting (BEPS Action 13). The additional guidance clarifies:

  • several interpretation issues related to the data to be included in the CBC report; and
  • the application of the model legislation contained in the Action 13 report, to assist jurisdictions with the introduction of consistent domestic rules

The guidance covers five new specific areas:

  • the definition of revenues;
  • the accounting principles/standards for determining the existence of and membership in a group;
  • the definition of total consolidated group revenue;
  • the treatment of major shareholdings; and
  • the definition of related party for purposes of completing table 1 of the CBC report.